M/S. Sava Healthcare Ltd, Pune vs. Assistant Commissioner of Income Tax, Pune
In the result, 70% of world profits are added in the hands of assessee under guise of Profit Split Method
ITA 1067/PUN/2017[2012-13]Status: DisposedITAT Pune27 Jun 2019AY 2012-13
Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.1062 To 1068/Pun/2017 यििाारण वषा / Assessment Years : 2007-08 To 2013-14
For Appellant: Shri Kishore PhadkeFor Respondent: Ms Nandita Kanchan
Section 143(3)Section 144CSection 144C(8)Section 92C(3)
…r, the said references were set aside and the Assessing Officer was directed to provide fresh opportunity of hearing to the assessee. 80. The Hon’ble High Court of Calcutta in latest decision in the case of PCM Strescon Overseas Ventures Ltd. Vs. DCIT (2017) 399 ITR 302 (Cal), judgment dated 11.08.2017 has decided similar jurisdictional issue as to whether the Assessing Officer should afford reasonable opportunity of hearing to the assessee concerned and thereafter, pass a speaking order. The assessee had two branch units at two countries apart from India and there was no business transaction between unit in Ind…